Marriage of Al-Zouhayli v. Al-Zouhayli

LANSING, Judge

(dissenting).

I respectfully dissent. Minn.Stat. § 518.-175, subd. 1 (1990) requires courts to grant “such rights of visitation * * * as will enable the child and the noncustodial parent to maintain a child to parent relationship that will be in the best interests of the child.” The court is further required to restrict visitation if it “is likely to endanger the child’s physical or emotional health or impair the child’s emotional development.” Minn.Stat. § 518.175, subd. 1. Requiring, as the trial court did, that appellant demonstrate the likelihood of abduction by a preponderance of the evidence is, I believe, too high a standard and not required by the statute.

In a careful and detailed order, the trial court found that respondent (a) testified untruthfully, (b) forged letters of reference and applied fake seals, (c) misstated work experience, (d) submitted fraudulent insurance claims, (e) submitted false statements to avoid paying sales tax, and (f) failed to comply with the court’s order for child support even though he was financially able to provide the support.

The court also found that (a) respondent has dual American and Syrian citizenship, *14(b) respondent was born in Syria and has extensive family ties in Syria and Saudi Arabia, (c) neither Syria nor Saudi Arabia are signatories to the Hague Convention and neither could be expected to assist in returning a child to this country, (d) courts of Syria and Saudi Arabia would be compelled to award custody of the child to respondent and no American court order would be enforced in Syria, (e) respondent has stated on more than one occasion that he intends to leave this country, (f) the child’s dual citizenship would permit issuance of a Syrian passport, (g) respondent frequently visits Syria and was last there in 1990, and (h) respondent will complete his medical training program in 1992.

The majority’s rejection of the evidence of endangerment as “based solely on speculation as to what respondent might do, and not on any past mistreatment of the child” (emphasis in original) demonstrates the problems inherent in the court’s application of the "likelihood” standard. There is substantial evidence in the record on which a trial court could reasonably impose supervised restricted visitation without subjecting it to a further criteria that probability of abduction must be shown by a preponderance of the evidence. Although supervised visitation is undeniably a burden on the noncustodial parent, it is a burden imposed by vital interests of the child. The 1992 legislature, recognizing the need for safe, supervised locations for noncustodial parents to visit with their children, provided funds to establish children’s safety centers. 1992 Minn.Laws ch. 571, Art. 10, § 17.